extremely important principle in Illinois

1982Ed. 2d 469, 475 , 90 S. Ct. 1189 , where, in the course of describing the doctrine, the court said: ‘ “ Collateral estoppel” is an awkward phrase, but it stands for an extremely important principle in our adversary system of justice.

1981Ed. 2d 469, 475 , 90 S. Ct. 1189, 1194 , as follows: “ ‘Collateral estoppel’ is an awkward phrase, but it stands for an extremely important principle in our adversary system of justice.

1981It means simply that when an issue of ultimate fact has once been determined by a valid and final judgment, that issue cannot again be litigated between the same parties in any future lawsuit * ° ( 59 Ill. 2d 557, 560 , 332 N.E.2d 461 , 462-63.) The only basis for relitigating a factual issue is where there has been some additional evidence or a “peculiar circumstance” which warrants reconsideration, or where there is an articulable reason for not presenting relevant evidence at the prior hearing.

1977It means simply that when an issue of ultimate fact has once been determined by a valid and final judgment, that issue cannot again be litigated between the same parties in any future lawsuit.” See also People v. Haran, 27 Ill. 2d 229 , 188 N.E.2d 707 ; People v. Williams, 59 Ill. 2d 557 , 322 N.E.2d 461 .

1978It means simply that when an issue of ultimate fact has once been determined by a valid and final judgment, that issue cannot again be litigated between the same parties in any future lawsuit. ***” *** This court noted in People v. Haran, 27 Ill. 2d 229, 231 , that the doctrine of collateral estoppel was “well defined” in Hoffman v. Hoffman, 330 Ill. 413 .

1977It means simply that when an issue of ultimate fact has once been determined by a valid and final judgment, that issue cannot again be litigated between the same parties in any future lawsuit.” See also People v. Haran, 27 Ill. 2d 229 , 188 N.E.2d 707 ; People v. Williams, 59 Ill. 2d 557 , 322 N.E.2d 461 .

1991It means simply that when an issue of ultimate fact has once been determined by a valid and final judgment, that issue cannot again be litigated between the same parties in any future lawsuit.’ ” (People v. Grayson (1974), 58 Ill. 2d 260, 263 , quoting Ashe v. Swenson (1970), 397 U.S. 436, 443 , 25 L.

1982It means simply that when an issue of ultimate fact has once been determined by a valid and final judgment, that issue cannot again be litigated between the same parties in any future lawsuit. »*<*’* <**”« * »’ ” As to the requirement of a valid and final judgment, the court noted in Relph v. Board of Education (1981), 84 Ill. 2d 436, 442-44 , 420 N.E.2d 147 , that finality, for purposes of applying res judicata (including therein collateral estoppel), required that the potential for appellate review had been exhausted.

1982It means simply that when an issue of ultimate fact has once been determined by a valid and final judgment, that issue cannot again be litigated between the same parties in any future lawsuit. »*<*’* <**”« * »’ ” As to the requirement of a valid and final judgment, the court noted in Relph v. Board of Education (1981), 84 Ill. 2d 436, 442-44 , 420 N.E.2d 147 , that finality, for purposes of applying res judicata (including therein collateral estoppel), required that the potential for appellate review had been exhausted.

1978It means simply that when an issue of ultimate fact has once been determined by a valid and final judgment, that issue cannot again be litigated between the same parties in any future lawsuit. ***” *** This court noted in People v. Haran, 27 Ill. 2d 229, 231 , that the doctrine of collateral estoppel was “well defined” in Hoffman v. Hoffman, 330 Ill. 413 .